Accessibility laws · France

France: RGAA & EAA Enforcement

In June 2026 a French court told Carrefour that an e-commerce site cannot be only slightly accessible. The Tribunal judiciaire de Caen ordered the retailer to make carrefour.fr and its mobile app fully accessible within six months, with a daily penalty for every day of delay and damages on top. The associations who brought it read that as accessibility being an obligation of result, where trying hard is not the standard. Later the same month the regulator put the French state's own tax ministry on formal notice. France runs two accessibility regimes at once, and both of them have just started moving.

Cap on the daily penalty alone: €300k
Public non-conformity fine: €50k
Turnover for statement duty: €250M
French WCAG methodology: RGAA

What the law is

France's accessibility duty starts with article 47 of a 2005 disability rights law. It reaches four categories of body, and the list is wider than public sector. Public law legal persons are in. So are private bodies delegated a public service mission, general interest bodies caught by a public financing, control or board appointment test, private bodies those organizations set up for the same purpose, and companies whose turnover passes a threshold. The threshold is not in article 47 at all, which trips people up. The statute leaves the figure to a decree, and the figure the regulator applies is €250 million of average annual turnover realized in France over the three preceding financial years. Turnover in France, not global turnover. For a large multinational with a modest French operation, that distinction is the whole answer.

Since June 28, 2025 a second regime sits on top of the first one. France transposed the European Accessibility Act through a 2023 law and its implementing texts, and it now reaches consumer-facing private services, which means e-commerce, banking, transport and telecoms. The microenterprise exemption lives in article L412-13 of the consumer code, and it covers providers with fewer than 10 employees where either annual turnover or balance sheet total is no more than €2 million. Both halves have to be true at once, so a 15-person company is covered whatever its financials. A different regulator supervises this track, which is why one company can end up answering to two regulators for two different parts of the same business.

Two things happened in June 2026 that changed what French accessibility law means in practice. Two disability associations, apiDV and Droit Pluriel, sued Carrefour France over carrefour.fr and the Carrefour mobile app. The Tribunal judiciaire de Caen found for them and ordered both fixed within six months, with a daily penalty for every day of delay after that, damages, and a costs award. It refused the requests to shut the service down and to publish the ruling. Its reasoning ran through the consumer code and article 47 together. Treat anyone telling you it was purely one or the other with care. The associations describe the result as accessibility being an obligation de résultat, an obligation of result, meaning you owe the outcome rather than your best effort. Read that as their reading of the decision. Three limits on it. It is one first-instance court. We could not get the order from the court's own service. And nothing we found says whether it was appealed. Then, on June 24, 2026, Arcom put the Ministère de l'Action et des Comptes publics on formal notice over impots.gouv.fr. So France has a court decision against a retailer and a regulator decision against the government, in the same month.

This applies to you if…

You are a French public body, or you deliver a public service online on one's behalf. The duty reaches public law legal persons, private bodies delegated a public service mission, general interest bodies caught by a public financing, control or board appointment test, and private bodies those organizations created for the same purpose. RGAA conformance and a published accessibility declaration apply to all of them.
Your company's average annual turnover realized in France, over the three preceding financial years, is above €250 million. That threshold comes from a decree rather than from the statute, so it can change without the law changing. Note what is measured. Turnover in France, not turnover worldwide.
You sell EAA-covered consumer services into France, such as an online store, banking, transport or telecoms. This track has applied since June 28, 2025, and it does not care about the €250 million figure at all. What it cares about is whether you clear the microenterprise line. Ten or more employees puts you over it. So does having fewer than 10 employees with both your annual turnover and your balance sheet total above €2 million.

What it technically requires

On the article 47 track you test against the RGAA, France's own methodology, currently version 4.1.2 with 106 criteria. Arcom describes the RGAA as implementing European standard EN 301 549 V2.1.2, which is itself based on WCAG 2.1. So the web criteria underneath are the European ones, tested on a French sheet. Do not stretch that into equivalence. Arcom does not. The RGAA is a web methodology, and the European standard reaches native apps, software and other technology it never tests. Passing the RGAA answers the RGAA. Version 5 of the RGAA is planned for the end of 2026, so anyone auditing to 4.1.2 today should know a new edition is close.
That leaves France pointing at two editions of the European standard at once, so it helps to know which is which. The RGAA sits on V2.1.2. The edition behind the presumption of conformity everywhere else in Europe is V3.2.1, published in March 2021 and cited in the Official Journal since February 12, 2022. Underneath both of them is WCAG 2.1 Level AA, so the success criteria you are tested against do not move. What differs is the test sheet and the non-web clauses around it. Two things are now in flight at the same time. A revision of the European standard carrying the web clauses up to WCAG 2.2 is drafted and working through ETSI's process, with no published version number and no date behind it, and RGAA 5 is due at the end of 2026. Nobody can tell you which lands first. Testing to WCAG 2.2 Level AA today survives either.
You have to publish an accessibility declaration that states a measured conformance rate, and a percentage is much harder to fudge than a claim. France reports it in three states, fully conformant, partially conformant, or not conformant. The declaration carries the audit report, the measured rate, a list of inaccessible content with the reasons, remediation plans, and how to complain. The conformity status has to be clearly visible on your home page, with the declaration and the plan reachable from there. It is a placement requirement as well as a document requirement. You also need a multi-year accessibility plan whose duration cannot exceed three years, broken into annual action plans.
Since June 2026 there is a French court decision saying an e-commerce site cannot be only slightly accessible, and that where the RGAA is the yardstick, every applicable criterion has to be met. One first-instance decision is not a new national rule, and we are not going to sell it to you as one. What it does do is take away the comfort the RGAA's own three-band reporting seems to offer. Partial conformity is a way of describing where you are. Nobody has ever said it was a defense.
On the EAA track you meet EN 301 549 and carry the accessibility information duties that come with it. The two tracks are enforced by different regulators, so satisfying one does not automatically satisfy the other. What they share is the underlying web success criteria. What differs is the testing methodology, the format of the document you publish, and how much beyond the web each one reaches.

All roads lead to WCAG. Start with Level AA, the legal standard or the full 55-rule library. Unfamiliar term along the way? The A to Z glossary decodes it.

This law expects a published accessibility statement, and regulators check for it first. Generate yours free →

How it is enforced

Arcom, France's media and communications regulator, took on digital accessibility supervision in September 2023, which means article 47 ran for 18 years with nobody effective enforcing it. That is the context for how much has been found since. The procedure runs in two stages. Sworn officers record the breach by procès-verbal, and Arcom then issues a public mise en demeure with a deadline. If you miss that deadline, Arcom can impose up to €50,000 per non-conforming service, and up to €25,000 for breaches of the declaration, multi-year plan and action plan duties. A further sanction is possible where the breach is still there six months later, and Arcom can publish the sanction itself. One nuance most summaries miss. For private companies above the €250 million threshold, Arcom's supervision covers the declaration duties rather than conformity itself, so the ceiling that applies to them is €25,000 and not €50,000.

The June 24, 2026 decision against the tax ministry shows what a French regulator actually looks at. Arcom listed ten grievances and five of them concerned the accessibility declaration alone. One declaration claimed 100% conformity while an audit measured 42.11%. Another dated from 2023 and had never been updated, despite the three-year rule, and the published action plan covered 2024 rather than the current year. The technical findings were ordinary. Tax notices went out as untagged PDFs with no structure, no titles and no language definition, and no accessible alternative was offered. A messaging dropdown menu could not be reached by keyboard or by a screen reader. A tax year menu needed a mouse. A rental income table had cells with no header associations. Not one of those is exotic. Arcom gave nine months for the technical failures and two months for the paperwork.

The DGCCRF, France's consumer protection and fraud authority, supervises the EAA services track. Its base sanction is a fifth-class contravention, €7,500 per infraction for a company and €1,500 for an individual. That rises to €15,000 for a company on a repeat offense, and it multiplies by the number of violations. Separately, after giving you a reasonable period to correct, it can impose a daily penalty of €3,000 for each day you stay non-compliant, capped at €300,000 in total. The €300,000 caps the daily penalty alone. The contravention fines sit on top of it. The DGCCRF also does not work alone, coordinating with Arcom, Arcep, the Banque de France, the ACPR and the AMF depending on your sector. And the honest note. No source we read records a DGCCRF sanction for digital accessibility yet, so this is a scale on paper rather than a pattern in practice.

The route that produced the Carrefour judgment is not a regulator at all. Two disability associations brought that case themselves, with support from a collective of jurists. So France has three ways this reaches you, Arcom on the public track, the DGCCRF on the private track, and associations in court. The third one moved first.

Key dates

2005Article 47 accessibility duty created
2019 to 2020Declarations, plans, and sanctions framework in force
Jun 28, 2025EAA track applies to private consumer services

What to do about it

Every obligation on this page is measured against WCAG, so the first step is knowing where you actually stand. Run the free 10-page scan for the machine-checkable slice. For the rest, we review the key journeys with an expert and a real blind screen-reader user, then attach a screenshot and a fix to every finding. $499, 5 business days.

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This law does not set the web requirement itself. It points at EN 301 549, the European accessibility standard, and that is where the requirement actually lives. Clause 9 of the standard carries WCAG 2.1 Level AA, so a site that already meets Level AA has met the web part of it. The rest of the standard covers ground WCAG never touches, including hardware, two-way voice, documents that are not web pages, and the support channels a customer reaches once the site has already failed them. Several countries adopt the standard under their own national designation, which carries the same requirements under a different name.

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Orientation only, current as of August 2026. Not legal advice, and no attorney-client relationship is created. For your specific situation, talk to your own lawyer.